JDA's one-of-a-kind Regulatory Affairs course is offered quarterly. Taught by 2 former career FAA managers and FAA GC it provides insight into FAA oversight and surveillance and how you can improve your working relation with the FAA and avoid enforcement action and fines. Go to www.jdasolutions.aero for more details
2. Program
1. Introductions and Expectations
2. JDA Background
3. Current Operating Environment
4. Goals and Objectives
5. FAA Processes and Procedures
6. Pro Active Solutions
7. Summary and Feedback
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3. Introductions and Expectations
Briefly state name and responsibilities
Please share your expectations for course
Please share example of FAA
interface/confrontation
Additional “war stories” during course
welcome – limit to 2 minutes please
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5. Current Operating Environment
Lawmakers Outraged by FAA Safety Violations
House Transportation & Infrastructure Hearing
April 3, 2008
Operators are no longer FAA customers
Whistleblowers are heroes
New Office under Chief Counsel (AAE)
CMO/FSDO Standardization - GAO Report
“Informal” Field Station Visit Results
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6. Current and Future
Operating Environment
Regulatory Compliance Environment
Evolution of Surveillance/Oversight Process
Air Transportation Oversight System (ATOS)
Part 121
System Approach for Safety Oversight (SASO)
Parts 121, 135, 145
Deploy in 2103
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7. Current and Future
Operating Environment
Safety Management System (SMS)
Parts 121, 139 Final Rule NLT Oct 2012
Other Certificated Operators 135, 145 TBD
New Entrant 121 operators
Must include SMS as part of formal application
SAS will provide oversight function and aligned with
SMS to ensure AFS “SAS” Safety Assurance System
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8. Key FAA HQ Management
Michael Huerta
Acting FAA Administrator
Peggy Gilligan
Associate Administrator
for Aviation Safety
John Allen
Director Flight Standards Service
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11. Record Fines
FAA
• Already collected twice as much
in fines then in final two years of
Bush presidency.
• Fines are weighing on carriers
that recently reported first
collective profit in 2 1/2 years.
“The pendulum has swung pretty
hard.’’
•Levied $4.77 million in penalties
since Obama took office, 84%
percent jump from 2007-2008.
• Proposed $77.4 million in fines
9/09 – 9/10 up 66 percent from
9/07-9/08.
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12. Significant Proposed Fines 2011 Part 121
Operator Type Date Proposed Fine Alleged Violation
Horizon Air 121 12/09/11 $777,000 Maintenance non compliance
Evergreen Air 121 11/11/11 $180,000 Operations non Compliance
Skywest 121 10/21/11 $160,000 Maintenance non compliance
Pinnacle 121 10/21/11 $1,000,000 Maintenance non compliance
Colgan Airlines 121 09/15/11 $1,892,000 Operations non Compliance
Alaska Airlines 121 09/09/11 $590,000 Maintenance non compliance
Capital Cargo 121 08/29/11 $298,500 Maintenance non compliance
American Eagle 121 08/10/11 $155,000 Operations non Compliance
American Eagle 121 07/11/11 $77,500 Maintenance non compliance
Atlantic Southeast 121 07/11/11 $132,000 Maintenance non compliance
Federal Express 121 07/08/11 $689,800 Operations non Compliance
Air Tran 121 06/23/11 $250,000 Maintenance non compliance
United Airlines 121 06/17/11 $584,375 Operations non Compliance
Atlantic Southeast 121 06/16/11 $425,000 Maintenance non compliance
Lynx Aviation 121 04/08/11 $350,000 Maintenance non compliance
Executive Airlines 121 03/30/11 $550,000 Maintenance non compliance
Skywest 121 01/18/11 $359,000 Ops and Maint non Compliance
Total Proposed 121 $8,470,175
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13. Significant Proposed Fines 2011
Part 145 and 135 and Manufacturers
Streamline Aviation 145 10/21/11 $241,200 Maintenance non compliance
Aviaton Technical Services 145 09/12/11 $1,100,000 Maintenance non compliance
Aviation Specialities 145 07/11/11 $77,000 Maintenance non compliance
Jet Aircraft Miami 145 07/11/11 $66,000 Maintenance non compliance
Pemco World Aviation Svcs 145 01/21/11 $170,000 Operations non Compliance
San Antonio Aerospace 145 01/20/11 $1,025,000 Operations non Compliance
Total Proposed 145 $2,679,200
Parachute Center 135 08/29/11 $269,000 Maintenance non compliance
Ameriflight 135 08/26/11 $262,000 Operations Non Compliance
Liberty Jet 135 07/11/11 $75,000 Operations Non Compliance
Apollo Aviation 135 07/11/11 $77,300 Maintenance non compliance
Jet Smart 135 07/11/11 $133,900 Maintenance non compliance
26 North Aviation 135 07/11/11 $81,000 Maintenance non compliance
Bimini Island Air 135 07/11/11 Certificate Revocation Regulatory Violation
ERA Helicopters 135 07/08/11 $194,249 Operations Non Compliance
Corporate Air 135 02/17/11 $585,275 Maintenance non compliance
Heli-Dudes* 135 01/06/11 $330,000 Regulatory Violation
Total Proposed 135 $2,007,724
Cessna Manufacturer 09/22/11 $2,400,000 Manufacturing Process
Boeing Manufacturer 06/27/11 $1,050,000 Regulatory Violation
Total Proposed Mfg $3,450,000
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14. Part 121 Fine Data Jan 2007 – Sept 2011
Fines Levied
Part 121 Cumulative Fines in $
$14,000,000.00
$12,000,000.00
$10,000,000.00
$8,000,000.00
$6,000,000.00
$4,000,000.00
$2,000,000.00
$-
Jul. 2007
Jul. 2008
Jul. 2009
Jul. 2010
Jul. 2011
Apr. 2007
Apr. 2008
Apr. 2009
Apr. 2010
Apr. 2011
Jan. 2007
Jan. 2008
Jan. 2009
Jan. 2010
Jan. 2011
Oct. 2007
Oct. 2008
Oct. 2009
Oct. 2010
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15. Part 121 Fine Data Jan 2007 – Sept 2011
Part 121 Cumulative # of Fines
250
200
150
100
50
0
Jan-07 Aug-07 Mar-08 Oct-08 May-09 Dec-09 Jul-10 Feb-11 Sep-11
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17. Part 145 Fine Data Jan 2007 – Sept 2011
Fines Levied
Part 145 Fines in $
$1,000,000.00
$900,000.00
$800,000.00
$700,000.00
$600,000.00
$500,000.00
$400,000.00
$300,000.00
$200,000.00
$100,000.00
$-
Jan-07 Sep-07 May-08 Jan-09 Sep-09 May-10 Jan-11 Sep-11
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18. Part 135 Fine Data Jan 2009 – Sept 2011
Fines Levied
Part 135 Fines $
1,600,000
1,400,000
1,200,000
1,000,000
2009 - 119 Actions
800,000 2010 - 107 Actions
600,000 2011 - 91 Actions
400,000
200,000
0
Jan-09 Jul-09 Jan-10 Jul-10 Jan-11 Jul-11
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19. Course Goals and Objectives
Understand FAA organization, ASI
authority, responsibilities and job
functions.
Be familiar with hierarchy of FAA
guidance, including regulations, orders,
handbooks, etc.
Learn to navigate FAA policy and
information via FAA.gov
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20. Course Goals and Objectives
Be familiar with FAA enforcement and other
investigative processes
How to investigate and respond to FAA
verbal communications and formal Letters of
Investigation (LOI).
Understand importance of documenting all
communications with FAA personnel.
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21. Topics to be Covered
FAA Processes and Procedures
FAA Organization
FAA Roles and Responsibilities
Operator Information
Inspector Job Functions
Surveillance
Investigations
Compliance and Enforcement
Proactive Approaches
“Regulatory Relations”
Regulatory Affairs Department
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22. Take Home Knowledge and Skills
Understand FAA Organization
Who to go for what problem
Understand hierarchy of FAA guidance
What’s more important?
USC, CFR, AD’s, Orders & handbooks, AC’s, Notices
etc. ???
Understand where to go within FAA information
databases to research questions
Tricks to navigating FAA.gov and other handy sites
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23. Take Home Knowledge and Skills
Why are documents so important?
Can be both prophylactic and offensive tools
Capture data, history is important
Proactive approaches
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32. Office of
Deputy Associate Rulemaking Quality,
Admin. For ARM Integration &
Aviation Safety – Executive Service
AVS-2 AQS
Office of Accident Office of Air
Investigation & Associate Admin.
Traffic Oversight
Prevention - AAI For Aviation Safety
AOV
AVS
Aircraft
Office of Aerospace Certification
Medicine Service
AAM Flight Standards AIR
Service
AFS
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33. Resources &
Gen Aviation & Program Mgmt Air Transportation
Commercial AFS-100 AFS-200
AFS-800
Civil Aviation Aircraft
Registry Maintenance
AFS-700 Flight Standards AFS-300
Service
AFS
Regulatory Flight Tech and
Support Procedures
AFS-600 AFS-400
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35. Additional Method
Employee List FSDO/CMO
FAA.gov may not contain
Northwest Mtn. all employee directories
Region
Organizations
You can always use
national employee
directory to find someone
How do we get there?
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45. General Information
(FAA Order 8900.1)
Volume 1
Chapter 1: Handbook Organization, Use, and
Revision
Section 1 : General Handbook Info
Paragraph 1-3: Standardization &
Coordination
C. Conflicts with other FAA Orders
Paragraph 1-5
A. Directive Information
B. Guidance Information
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46. Inspector Conduct
(FAA Order 8900.1)
Volume 1
Chapter 3: Inspector Responsibilities,
Administration, Ethics, and Conduct
Section 1 : Responsibilities of ASI
Paragraph 1-156
Section 2: Personal Ethics and Conduct
Paragraph 1-176
A. Unique Responsibilities of ASI
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48. Surveillance
(FAA Order 8900.1)
Volume 6
Chapter 2: Parts 121, 135, and 91 Subpart K
Inspection
Section 1: General Policies and Procedures for
Surveillance
Paragraphs
6-165: Introduction
6-166: Objective of Surveillance Programs
6-168: Planning and Executing
Surveillance Programs
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50. Repair Stations Surveillance
(FAA Order 8900.1)
Volume 6
Chapter 13: Enhanced Repair Station Oversight
Section 1: Introduction
Paragraph 6-2871
A. Goals, B. Initiatives, D. Components
Operator Responsibilities
14 CFR 121.363
Repair Station Responsibilities
14 CFR 145.205
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51. Surveillance Conduct
(FAA Order 8900.1)
Volume 6
Chapter 2 Inspections, (14CFR119.59)
Section
3 General Inspection Practices and
Procedures.
Paragraph 6-214: Conducting an Inspection
B. Advance Notice of Inspection
D. Inspector Conduct
E. Concluding inspection
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52. Air Transportation Oversight System
ATOS Surveillance
(FAA Order 8900.1)
Volume 10
Chapter 1. General
Chapter 2. Procedures for Design and Performance
Assessment
Chapter 3. Risk Management Process
Chapter 4. Air Carrier Evaluation Process
Chapter 5. Off-Hour Surveillance Assessment
Decision Aid
Chapter 6. The Certification Process of 121 Air
Carriers
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53. FAA Order 8900.1
(Formerly ASI Handbook)
Volume 10
Chapter 5. Off-Hour Surveillance Assessment
Decision Aid
Section 1
Paragraph 10-393
A. Identifying and Recording Off-Hour Activity
B. Necessity for Additional Off-Hour Surveillance
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61. Compliance & Enforcement
(8900.1)
Volume 14
Chapter 1: Introduction to Investigation and
Compliance Related Tasks
Section 1 FAA Compliance Philosophy
Paragraph 14-1
A. Compliance and Enforcement Differences
B. Relating Compliance and Enforcement to Other
Work Functions.
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62. Compliance & Enforcement
(2150.3B)
Chapter 2 Policy and Objectives
2a. FAA’s Mission and Authority
2b. Objective of Compliance and
Enforcement Program
Ultimate Goal is to prevent occurrence of
violations.
First priority of FAA investigative personnel
is to correct ongoing noncompliance.
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63. Compliance & Enforcement
(2150.3B)
Chapter 2 Continued…
3d. Notifying Persons of Potential Violations
Chapter 4: Investigation of Violation
Applying Findings to Regulations Believed
Violated
8a. Enforceable Regulations
8c. Burden and Standard of Proof
8d. Relevance and Materiality Legal
Comment
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64. Compliance & Enforcement
(2150.3B)
Chapter 4 Continued…
Paragraph 9: Letter of Investigation and
Response
9a. General
9b. Preparation of an LOI
9c. Sending the LOI to the Apparent Violator
Sample LOI
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65. Compliance & Enforcement
(2150.3B)
Chapter 4 Continued…
Paragraph 10: Evidence
10c (2): Witness Interviews
10c (3): Conducting Interview
Record of Interview
Record of Telephone Conversation
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66. Compliance & Enforcement
(2150.3B)
Chapter 5: Actions and Responsibilities of FAA
Paragraph 2: Selection of Enforcement Action
Paragraph 3: Admin. Action
3b. Warning Notice
3c. Letter of Correction
Paragraph 5: Informal Action
Paragraph 6: Re-inspection & Re-examination
Sample Letter Requesting Reexamination
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67. Compliance & Enforcement
(2150.3B)
Appendix F. Enforcement Decision Process
1. Introduction
a. Purpose
b. EDP Worksheet
2. Applying the EDP
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68. Compliance & Enforcement
(8900.1)
Applying EDP (continued)
Volume 14
Chapter 1: Introduction to Investigation and
Compliance Related Tasks
Section 8: Enforcement Decision Process
EDP worksheet
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69. Compliance & Enforcement
(2150.3B)
Chapter 2: C&E Policy and Objectives
Paragraph 4: Responsibility for Determining
Legal Enforcement
a. General
b. Responsibilities of FAA investigative Personnel
Responsibilities
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70. Compliance & Enforcement
(2150.3B)
Table of Sanctions
Appendix B
Classification of Air carrier
Civil Penalty Ranges
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72. Responding to Investigations
How operators should conduct internal
investigation
Responding to LOI
When and how to respond to FAA
See files from Appendix B & D of SOP
Manual
SOP “B”
SOP “D”
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73. FAA Order 8900.1
(Formerly ASI Handbook)
Volume 1 General Guidance and Information
Chapter 2 FAA and AFS History, Organization,
and Regulatory Responses
Section 2 Title 49, United States Code
Paragraph 1-118 Air Carrier Responsibilities for
Public Safety
Section 44702(b), 44709, 44713b, of 49 U.S.C
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74. Operator Responsibilities
14 CFR 119 & 121
Regulation 119.59 Conducting Tests and
inspections
Certificate holder must
Regulation 121.135 Manual Contents
Manual must contain
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75. Operator Responsibilities
Operations Specifications
14 CFR
119.43 - Certificate holder’s duty to maintain
operations specifications
119.49 – Contents of operations specifications
Volume 3 General Technical Admin.
Chapter 18 Operations Specifications
Section 1 Background Information
Paragraph 3-679; 3-681 Availability of OPSPECS
to Crew members and other employee
personnel.
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76. Non-Compliance Resolutions
Threat of Enforcement via OPSPECS
119.51 Amending Operations Specifications
Best
Practice!
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80. Reasons not to attack FAA
Analyze, Learn and GET OVER IT
Constant state of angst, anxiety and anger
WILL not allow you to do your job
FAA gets 51% of vote and is 800lb Gorilla
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81. Reasons not to attack FAA
Public perception
Individuals, with whom you are dealing, may
not accept concept, but regulatory process
can be cooperative
Your objective – move to positive relationship
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82. Reasons not to attack FAA
In your best interest to have relationship that is:
Positive,
Proactive,
Preventative
Cooperative
“I’m OK, You’re OK” Relationship
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83. Positive Regulatory Relationship
Key attributes for person(s) assigned to be FAA POC:
Easy to work with
Positive attitude
Polite
Has ready smile
Listens to learn
Cool under pressure, maybe having quiet confidence
Has firm handshake
Makes comfortable eye contact
Remembers names
Arrives early
Follows up consistently, thoughtfully and aggressively
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84. Who is your FAA Inspector?
Maybe experienced veteran
Listen attentively and learn
More likely to exercise
judgment
More likely
Recent graduate of FAA
Oklahoma City Academy
Has read CFRs at least once
Insecure, yet infallible
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85. Who is your FAA Inspector?
Post CSI strict constructionist
Aware of Oberstar hearings where FAA
was excoriated
Principals or manager may not be able to
control her/him
Whistle blower protection
Not worried at all about what it costs you
or whether it makes good operational
sense
86
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86. Who is your FAA Inspector?
FAA “administrative ease of
enforcement/tracking” is actually valid
criteria
Truly believes that what they want is
solely safety driven
Not evil person, wants to do his/her best
Understand their agenda
87
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87. No truth that FAA recruits only from:
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88. Encounter with FAA person
Who?
Where from?
Why here?
What is agenda?
What can I do to help?
What can I learn from this encounter?
89
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89. Encounter with FAA person
Who
First meeting with him/her?
Get biz card or ask name and write it down
Ask for credentials – “show me your badge”
Try to “deflate” situation
Ask informal questions (how’s Wx at home;
how was your flight; how many kids do you
have)
Make it clear that you are not anxious
Move meeting to your turf, quiet place
Offer to get coffee, water or soda
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90. Encounter with FAA Person
Who Continued 1st meeting
Understand his/her authority and interest
Inquire why the visit
If enforcement, remember all of “rules” that
you learned during class
If not, listen carefully to what FAA person is
trying to accomplish and LEARN
Take good notes
At end of meeting, get concurrence
Action items and IOUs
Set response dates
Meet or exceed them
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91. More Who Items
HARD HEADED
Document it, but do it
Assign right people
Keep detailed log
Make considered decision when to go for the “coup
de grace”
My Boss made me do it
May not just be excuse
Create legitimate reasons to meet with boss
Meet boss’ agenda
Work to reduce friction
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92. Encounter with FAA Person
Who – had previous meeting
Review previous notes
Touch on any personal relationships
established
Kids, sports, interests, work experience
Be CERTAIN to reintroduce whatever agenda
(office or personal) that you identified before
Mention any actions that you have taken or have
initiated along that agenda
Follow all ROE mentioned in first encounter
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93. Encounter with FAA Person
Where from
If you do not know where from, ask
Remember organizational chart lessons:
If from DC (AVS, AFS,AIR, etc.)
Person has specific job scope (ask)
Inquiry is VERY likely to be on policy
If from your region or another region
Ask about job scope/focus
May be special inquiry/investigation
If it is, should have called for appointment – mention/ask
If from your CMO/FSDO
Could be routine
Ask!!!
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94. Why Here/What is Agenda?
IMMEDIATELY assess agenda
Is there enforcement investigation open?
If answer is YES, then
Questions you should ask yourself…
BE CAREFUL WHAT YOU SAY
Take comprehensive notes
If answer is NO,
Opportunity to refine/improve relationship
Know their agenda and specific hot buttons
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95. What can I do to help
Positive, responsive attitude buys GOODWILL
It helps to have “salesperson’s” skill set
Seemingly stupid questions do not necessarily mean
FAA bad attitude, may just reflect lack of knowledge
about real world of operators
Take initiative; suggest solutions that BOTH
Make good operational sense
Meets FAA, office and person’s agenda
YOU ARE INFINITELY MORE LIKELY TO DISCERN SUCH
OPTIONS
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96. What Can I Do To Help
If FAA person makes 1st suggestion, you will
have to “argue” away from that point
Set deadlines, at least meet them; hopefully
exceed them
Try to say “NO” in positive response such as,
I’d like to get you those documents, but let’s
consider two options
Someone from my shop will make copies and have them
ready by 3pm in two work days
I can have books available for you to copy by 4pm
today?
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97. What Can I Learn From Encounter?
One approach does not fit all
Document, Document, Document
Sloppy, inaccurate records = blood in water for
investigators
Maintained, well organized records lead to
inspector boredom and case closure
The ultimate in FAA “administrative ease”
Make their job easy and...
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98. What Can I Learn From This Encounter?
Specific Reactions
May be headache to adjust
Need to do calculus– short term pain v.
long term peace
Do NOT compromise PRINCIPLES
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99. What Can I Learn From This Encounter?
Review/ Revise Regulatory Action Plan
based on each encounter
Soon after encounter
Write report about substance and person(s) involved
Soon afterwards is important
Subtle messages/signs will be FRESH and mean more
Facial expression may hint whether request is demand or nice-
to-have
Place specific request in context of entire conversation
Brief your management
Send actions/IOUs and report to FAA for confirmation
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100. What Can I Learn From This Encounter?
FOLLOW UP; convey that FAA agenda is
matter of importance to company
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101. Positive Regulatory Relations
Set own FAA agenda – proactive not
reactive
Improve records/systems
Incorporate specific hot buttons
Tell PMI or POI about scheduled company
enhancements of non-regulatory systems
Share with FAA future commercial
developments
Create reasons to bolster relations with
FSDO, region, HQ leaders
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102. Positive Regulatory Relations, p.2
Conduct regular Meetings with FAA
Meet with FSDO or CMO manager monthly
Exchange info– LISTEN and LEARN
Follow what’s going on in their world and be
sensitive
FAA budget likely to be cut
Fed pay likely to be frozen
Congressional hearings
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103. Positive Regulatory Relations, p3
Get intelligence on FAA trends/issues from your Washington
Office, Trade Association or legal counsel
Interpret what appointments mean
Use as reasons to keep in contact with FAA senior
leadership
Create “safety net” for when bad things happen
Too late to create positive relationship when major
problem is announced
Every bit as importantas preventative maintenance
Use valid reason as predicates for meetings
Ask your Washington office/trade group to include you in
meetings with Hill staff (members only if your staff says it is a
great idea)
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104. Refresh your Regulatory Relations
Not static plan
Periodically review relationships, goals and
plans
Do not get overconfident
Equal weight to other operational plans
Choose staff with the right skills
Make position to be predicate to future promotion
within organization
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105. Establish Regulatory Affairs Group
Centralize Reg. Affairs activity
Locate office for FAA convenience/access
Put under Safety maybe legal
Head by MD
SOP
Train staff
Processes, procedures, forms
Collect data
Coordinate responses as focal point
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106. Establish Positive Relationship
Make FAA Agenda Your Priorities
Pay attention to FAA local agenda
Don’t compromise if your are rock solid certain
Look for opportunities to involve FAA early
Non-crisis meetings
Have regular meetings or CCs
Know your PI
Learn their Goals and Objectives
Go beyond local FAA but keep local in loop
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107. Improve Your Regulatory Knowledge
Use tools from course
Go Beyond FAR
Preamble, NPRM and FR comments
ACs’, 8900.1, AD’s and associated references
Contact FAA POC/author
Raising the Bar
Keep it generic – no dispute
Keep records of research, calls - details
FAA Buddy System
Control access, have sign in
Escort
Document visit, documents copied, questions
Document visit and actions
SOP with all line stations
Follow up email/call confirming actions/dates
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108. Outcome
Proactive business approach not reactive
Standard approach for FAA interface
Fewer fines and LOIs
Improved FAA relationships
Positive impact on corporate/safety culture
Improved record keeping
Less crisis management
Lower operating costs
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109. After the Course
Questions about Course Material?
Contact instructors by email or phone
Need Support with FAA Issue or LOI?
JDA monthly subscription service or on
demand/by the drink
Tailored to company size
Former FAA assigned as rep/assist
Lessons learned
Call JDA at 301-941-1460 ext 140 for details or
email JDA at info@jdasolutions.aero
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